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Income Taxes › Pass-Through Entities

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Seward & Kissel LLP

House Tax Bill 2025

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On May 12, 2025, Republicans in the House of Representatives introduced the One, Big, Beautiful Bill of 2025 (the “House Bill”). The House Bill comes out of the House Ways and Means Committee after weeks of internal drafting...more

Eversheds Sutherland (US) LLP

New York State releases Fiscal Year 2026 Executive Budget

Eversheds Sutherland (US) LLP on

On January 21, 2025, New York Governor Hochul released her Fiscal Year 2026 Executive Budget and accompanying legislation (the Budget Bill). The Budget Bill includes a middle-class tax cut, a temporary personal income tax...more

Buchalter

Tax Relief and Recovery: Key Considerations for Los Angeles Residents Affected by Recent Wildfires

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We at the Buchalter law firm understand that many have suffered greatly as a result of the recent wildfires. The loss of life, and the loss of homes with memories is, of course irreplaceable....more

Buckingham, Doolittle & Burroughs, LLC

Challenges Businesses Face with Ohio State and Local Taxes

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From understanding how businesses are taxed to navigating changes in Ohio tax regulations, it’s important to be aware of potential tax hurdles and how to proactively avoid them. This article from Buckingham, Doolittle &...more

Foodman CPAs & Advisors

Pass-Through Entities are Under Scrutiny by IRS

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On 10/22/24, the IRS announced that is has officially commenced operations of the newly established pass-through field operations unit within its Large Business and International (LB&I) division, which was announced last...more

Holland & Knight LLP

A Look at Search Funds and Section 1202 Qualified Small Business Stock

Holland & Knight LLP on

Search Funds should consider the availability of the tax benefits of Section 1202 in connection with their acquisitions. The upside, if properly structured, can be significant. Section 1202 has gained popularity likely due to...more

Baker Donelson

SALT Select Developments - May 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Miles & Stockbridge P.C.

Md. Comptroller Offers Relief for Missed 2023 PTE Elections

Miles & Stockbridge P.C. on

Maryland Comptroller Brooke Lierman issued a letter Feb. 28 to address the challenges and concerns of tax practitioners regarding the policy and procedural changes to pass-through entity (PTE) filings and payments. Most...more

Williams Mullen

2023 Developments in Virginia Taxation

Williams Mullen on

A Summary Review of Tax Legislation, Court Decisions, Opinions of the Attorney General and Published Rulings of the Tax Commissioner Published from January 1, 2023 through November 10, 2023....more

Gray Reed

Phantom Income: The Spooky Side of Taxation

Gray Reed on

There’s a hidden tax horror behind pass-through entities, cancellation of debt, and even prizes, winning, and awards: “phantom income.” It even sounds scary, right? And when it comes to one’s tax liability, it can be...more

Venable LLP

Nonresident Owners Selling a Business with California Contacts? Be Wary of Selling Through a Conduit Holding Entity

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Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

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Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

Allen Barron, Inc.

California and IRS Extended Income Tax Deadlines are Rapidly Approaching

Allen Barron, Inc. on

The California and IRS extended income tax deadlines are rapidly approaching as we near the deadline in mid-October.  In the first few months of 2023 California and the IRS extended income tax deadlines and associated...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

Skadden, Arps, Slate, Meagher & Flom LLP on

On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

Bradley Arant Boult Cummings LLP

Alabama DOR Grants Extension to Make PTE Tax Election for 2022 Tax Year

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In 2021, the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The Alabama Electing...more

Miles & Stockbridge P.C.

Maryland Updates Pass-Through Entity Election Requirements

Miles & Stockbridge P.C. on

The Maryland Comptroller’s Office issued a Tax Alert on April 11, 2023 addressing policy and procedural changes to pass-through entity (PTE) filings and payments. For tax years beginning after Dec. 31, 2022, PTEs are required...more

Polsinelli

Beware, the IRS is Coming: More IRS Audits to Focus on High-Net Worth Individuals and Passthrough Entities

Polsinelli on

After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more

Williams Mullen

Virginia Dept of Tax Issues Clarifying Guidance for Recent Changes to Pass-Through Entity Tax

Williams Mullen on

The General Assembly enacted legislation (H.B. 1456 and S.B. 1476) during its 2023 Regular Session that removed some of the barriers for qualifying for Virginia’s Pass-Through Entity Tax (PTET) election and altered how PTET...more

Eversheds Sutherland (US) LLP

Georgia’s 2023 legislative session ends with significant tax legislation

Eversheds Sutherland (US) LLP on

During the 2023 legislative session, the Georgia General Assembly passed significant tax legislation including decoupling from IRC § 174, imposing sales tax on certain digital goods, and revising eligibility for the...more

Williams Mullen

Virginia’s General Assembly Enacts New Tax Legislation in 2023 (Chart Included)

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The table below summarizes the tax legislation enacted by the General Assembly during its 2023 Regular Session and approved by Gov. Youngkin that will become law on or before July 1, 2023. Please note that any legislation...more

Williams Mullen

Increased Flexibility for Pass-Through Entity Tax Election Passes Through General Assembly

Williams Mullen on

During its 2023 Session, the Virginia General Assembly passed legislation, H.B. 1456 and S.B. 1476, that removes some of the barriers for participating in Virginia’s elective Pass-Through Entity Tax (PTET)....more

Sands Anderson PC

Update on Potential Tax Savings Opportunity: Virginia’s Pass-through Entity Tax and SALT Cap Deduction Workaround

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For individual owners of pass-through entities, such as partnerships, limited liability companies (“LLCs”), business trusts, and S Corporations, Virginia’s elective Pass-through Entity Tax (“PTET”) offers potential federal...more

Fox Rothschild LLP

Omnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current Cases

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On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new language relating to donations of conservation easements by...more

J.S. Held

Don’t Double Tax Your Business: How The PTE Tax Can Impact the Valuation of Pass-Through Entities

J.S. Held on

Taxes can have a significant impact on the value of a business. Pass-through entities such as S-Corporations and partnerships generally do not pay any taxes since the income is passed through to the individual shareholder or...more

Kohrman Jackson & Krantz LLP

Ohio Enacts New Elective Pass-Through Entity Tax

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Last month, Governor Mike DeWine signed Senate Bill 246, authorizing Ohio pass-through entities (PTE), including S corporations, partnerships and limited liability companies taxed for federal income tax purposes as...more

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